Over at Cady Bar the Door, my friend David Smyth wrote yesterday about SEC v. Gincel -- which he dubbed "the Smallest Insider Trading Case in All of Captivity." In that case, which the SEC filed on March 1, 2016, the SEC alleged that the defendant's insider trading resulted in a profit of a whopping $1,083. Smyth wrote:
I sometimes warn clients that the SEC will occasionally bring a dinky insider trading case just to show there’s no floor or de minimis level it thinks is okay. And to look at this case, there’s not a lot of room to go down. I’ve never heard of a lower disgorgement figure, and am prepared to declare this case the smallest one ever. Please write if you’ve seen one that’s dinkier.
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